Substance Called—CRA Wants Its Residual Back: Bill C-15, OECD delineation, and the 30-day documentation squeeze episode artwork

EPISODE · Jan 23, 2026 · 16 MIN

Substance Called—CRA Wants Its Residual Back: Bill C-15, OECD delineation, and the 30-day documentation squeeze

from The Transfer Pricing Show · host Josh Post

CRA’s been aggressive for years—now Canada wants OECD-style “actual conduct” baked into the statute. Bill C-15 shrinks the doc clock to 30 days and makes “contracts say” a weaker defense when reality says otherwise. If your residual lives offshore but decisions live in Canada, expect the phone to ring.

Episode metadata supplied by the publisher feed · Published Jan 23, 2026

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Substance Called—CRA Wants Its Residual Back: Bill C-15, OECD delineation, and the 30-day documentation squeeze

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